ML19256F353

Submits Brief Summary of Position Re Items Questioned in NRC 791030 Ltr.Response Will Indicate Implementation Date of 800101.Detailed Response Will Be Forwarded Not Later than 791214

ML19256F353
Person / Time
Site:	Fort Saint Vrain
Issue date:	12/12/1979
From:	Swart F PUBLIC SERVICE CO. OF COLORADO
To:	Kunzmycz G Office of Nuclear Reactor Regulation
References
P-79298, NUDOCS 7912180595
Download: ML19256F353 (3)

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m. A2 December 12, 1979 Fort St. Vrain Unit No. 1 P-79298 Mr. George Kuzmycz, Project rianager Division of Project Management Special Projects U. S. Nuclear Regulatory Commission Washington, DC 20555 Docket No. 50-267

Subject:

Fort St. Vrain Unit No. 1 TMI Lessons Learned Ref: 1) NRC Letter to PSC, 9-13-79

2) PSC Letter to NRC, 10-29-79 (F-79249)

3) NRC Letter to PSC, 10-30-79

Dear Mr. Kuzmycz:

Pursuant to our telephone conversations with you and members of your Staff on December 10, and December 11, 1979, this letter shall serve as an interim, general response to follow-up actions on the TMI-2 Lessons Learned Task Force Report contained in the above referenced correspondence.

Based on conversations with the NRC Staff subsequent to our October 29, 1979 submittal (Reference 2) several areas were identified in which our response was not adequate. We have reviewed these areas and are prcparing a detailed response to the questions raised as a part of our response to the October 30, 1979 letter (Reference 3). Our detailed response is scheduled for submittal to you on December 14, 1979. In the interim the following represents a brief summary of our position with reference to those items questioned. The items are keyed to the paragraph numbers of Lessons Learned Task Force recommend-ations/ requirements.

2.1.6.a Integrity of Systems Outside Containment The Staff questioned our October 29 response with reference to assuring leak tightness of systems subject to contain radioactive fluids outside containment.

Our detailed supplementary response, as discussed with you in various telecons, will address our ability to verify leak tight-ness of these systems utilizing area, process, and equipment radiation monitors which provide a continuous assessment of system integrity.b@

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December 12, 1979 Mr. George Kuzmycz Page two 2.1.6.b Design Review of Plant Shielding The staff questioned our October 29 response in that it was not clear that modifications that may be required as a result of our design review would be implemented by January 1, 1981.

Our supplementary response will comit us to making nece-ssary modifications by January 1,1981.

2.1.8.a Improved Post Accident Sampling Capability The staff questioned our October 29 response on the basis no implementation date for required modifications was made and that interim procedures were not addressed.

Per our telecons with you, our detailed supplementary response will comit us to complete necessary modifications by January 1, 1981. Our detailed supplementary response will also describe our methods for assessing fuel damage and will describe our methods for sample analysis based on accident conditions set forth in the Fort St. Vrain FSAR. Given the conditions of an HTGR versus a LWR, we feel our position meets the intent of the NRC position and that existing procedures fulfill the requirements for the January 1, 1980 implementation date.

2.1.8.b Increased Range of Radiation Monitors The staff questioned our response in that the implement-ation date for modifications that may be required as a result of our design review was not clearly specified. Additional questions were raised on the use of interim procedures.

Our detailed response will clearly specify our intent to meet the January 1,1981 implementation date. Our response will also address our capabilities to meet interim requirements by January 1,1980, within the envelope of analyzed Fort St. Vrain accidents.

2.1.8.c Increased Range of Radiation Monitors The Staff questioned our response of October 29, 1979, in that the use of portable iodine monitoring equipment was not addressed.

Our detailed supplementary response will indicate our intent and capability to monitor for iodine in areas that require habita-bility or access utilizing portable air samplers and multi channel analyzers. Thk sampling and analysis capability will be in place by January 1,198i .

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December 12, 1979 Mr. George Kuzmycz Page three 2.2.1.b Shift Technical Adviser The Staff indicated that the implementation date for training was not specified.

Our response will indicate that training will be provided to meet the January 1,1981 date and will clarify our position on training with reference to new employees filling this position.

2.2.1.c Shift and Relief Turnover Procedures The Staff found the implementation date of March 1,1980 to be unacceptable.

Our revised response will describe our turnover procedure and will indicate that procedures will be in effect by January 1, 1980.

2.2.2.b On Site Technical Support Center The Staff found that our October 29, 1979 response did not specify the implementation date for the permanent On-Site Technical Support Center.

Our response will indicate an implementation date of January 1, 1981.

We trust that the above items, although briefly summarized, indicate our position with reference to questions raised by the Staff. Our detailed response will be forwarded to you no later than December 14, 1979.

Very truly yours, PUBLIC SERVICE COMPAf Y OF COLORADO

. f^r L Frederic E. Swart Nuclear Projects Manager FES:11 1608 257